Without any Expression of Manifest Exclusion, Claim Term Would Not be Limited to the System Disclosed in the Specification

The court affirmed the grant of summary judgment of non-infringement. On appeal, the patentee, Imaginal, argued that the district court erred in construing the term “vision guidance system” in the phrase “without the use of a vision guidance system.” The accused re-designed device used a vision guidance system and therefore the accused device could not infringe under the court’s construction, which did not limit the “vision guidance system” to any particular system. Imaginal argued that the court erred by not construing “vision guidance system” to be limited to the specific “vision guidance system” disclosed in the patent.

The Federal Circuit disagreed with Imaginal, holding that the specification did not express any manifest exclusion or restriction to the meaning of “vision guidance system,” and therefore this term would not be limited to the vision guidance system disclosed in the patent. For example, the patentee could have, but did not, define the term “vision guidance system” to have any special meaning, and more than one “vision guidance system” was disclosed, making it difficult to know which one would be included in the meaning of “vision guidance system.”

Imaginal Systematic, LLC v. Leggett &Platt, Inc., Case No. 2014-1845 (November 10, 2015); Opinion by: O’Malley, joined by Schall and Moore; Appealed From: United States District Court for the Central District of California, Klausner, J. Read the full opinion here.